Epstein Secrets

nduct as defined in It U.S.C. § 2423(0. with minor female., in violation of Tide United States Code, Section 2423(b), all In viobation of Title It, United Stases Code, Section 2427(e); wing a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor female. to engage

United Sines, the State of Florida, and the Defendant soil) be sewed by the following proodum, THEREFORE, on the authority of It. Alexander Acosta, United Slates Attorney for the Southern District of Florida, prosecution in this District foe these offenses shall be defined in favor of prosecuticm by the Stat

f civil or criminal liability or a waiver °forty jurisdktional or other defense as to any person whose name does not appear on the list provided by the United Stale. 10. Except es to those individuals who elect to proceed exclusively under IS U.S.0 f 2255, as set (whin penigntph (St manta. neither Epstein's s

gain time he eamwd during his period of Incer«ration. I3. the ponies anticipate Nat this agreement will not be mede pan of any public record. if the United Slates receive, e Freedom of Information Act request or any compubory worm conunanding the disclosure of the agreement, int will provide notice to Epstein

." United States I. lordm, 915 F.2d 622, 628 (11th Cir. 1990) (quoting Rodriguez,. United States, 480 U.S. 522, 525 (1987) (itself quoting Russell° I. United States 464 U.S. 16, 23 (1983))). There is no basis for departing from that rule. Given the strong evidence that Congress did not intend retroactively to ap

phrase. See, e.g., United States'. Garcia-M, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States I. Yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United Statosi. Ellis 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);

er Defendant Epstein's defense of the civil actions filed against him violates the non-prosecution agreement between Epstein and the United States. The United States' position in this matter would be very helpful to the Court and, accordingly, the Court requests that the United States appear at the hearing. Base

tion apaisai him h irntinned for any offense that usis the 'objecter0e grandjuria inwangation, il may be by way of anInfonnwion sIgned and filai by the United States Anone); end hereby nives Ma rie to be Indktcd by e gnnd jury as ha any aie offense, lit tyy lff hie 6of 7 Case No. 08-80736-CV-MARRA P-011809 EFTA0

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States,. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- Case No. 08-80736-CV-MARRA P-011863 EFTA00192909 Ca

slated with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident."' Id. (quoting Jsbrandtsen Co. I. Johnson, 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

lculation of the offense levels under United States Sentencing Guidelines Manual (USSG) §§ 2G2.I and 2G2.2 (1998).FNI I FNI I. The 1998 edition of the United States Sentencing Guidelines Manual was applied in this case due to concerns about possible ex post facto problems that might arise from subsequent amend

prft—H... 12/18/2007 EFTA00191996 Page 13 of 13 77 Fed.Appx. 371 77 Fed.Appx. 371, 2003 WL 22331999 (C.A.6 (Ohio)) (Cite as: 77 Fed.Appx. 371) United States' Lyckman, 235 F.3d 234, 237-40 (5th Cir.2000). The term "sadism," which is the most relevant to this case, is defined as the " infliction of pain u

ent when it is based on consent from a third party whom the agents reasonably believed (even if erroneously) to have common rt.over the premises. United Stater 979 F.2)77, 79 (6th Cir.1992) (quoting Illinois Rodriguez, 497 U.S. 177, 110 S.Ct. 93, III L.Ed.2d 148 (1990)). B. Attempted Enticement of A M

y constitutes reversible error. Conclusion For these reasons, the judgment of the district court is affirmed. AFFIRMED C.A.7 (Ind.),2007. U.S. I. Johnson 495 F.3d 536 END OF DOCUMENT C 2008 Thomson/West. No Claim to Orig. U.S. Govt. Works. Page 9 hups://web2.westlaw.com/print/printstream.aspx?sv=F

cific information available. Conviction affirmed. 2422(b) No Information 40 EFTA00226356 COURT CASES FACILITY FACTS/COMMUNICATION CHARGE United States' Messano, 114 Fed. Appx. 785 (9th Cir. 2004) Unpublished Internet Defendant developed relationship over a period of several months on the Intern

exclude pre-Miranda statements and evidence from bag denied. See U.S., Vasquez, 2003 U.S. Dist. LEXIS 2339 (D. Me. 2003) infra N.D.N.Y. U.S. I. Johnson, . 2005 U.S. Dist LEXIS 52 (N.D.N.Y. 2005) Internet Internet chat room; 37 yr-old male met 13 yr-old; 16 yr-old and one other under 18 yrs-old